Yeah, the steps follow exactly what happened at VW with DieselGate. The diesel emissions lies were found out because some enterprising person set up an emissions testing system and drove the car in real world scenarios with it to verify the claimed emissions.

There's no reliable way to verify a foundation model has been trained on a particular piece of proprietary data. If an API key is ingested, hopefully the foundation model is wrapped in enough moderation that the raw API key oberserved during training is not recited verbatim in the output.